Woodstock Institute submitted a comment letter to the Office of the Comptroller of the Currency to request that the OCC take action to establish meaningful third party supervision requirements for national banks that partner with tax preparers to make refund anticipation loans (RALs) A recent ruling by the FDIC establishes a new standard requiring banks to supervise and monitor their partner tax preparers for compliance with safety and soundness and consumer protection laws. The letter argues that the same standards should be adopted by the OCC for the national banks engaged in RAL lending.

Woodstock asks federal banking regulators to modify CRA regulations to ensure purchsed loans are not resold merely to inflate their value for CRA purposes, and pro rate CRA credit for mixed-income housing development.

Woodstock Institute endorses the “Protecting Consumers from Unreasonable Credit Rates Act” as introduced by Senator Richard Durbin.  The Act limits the total cost of consumer credit to 36 percent.

Comment letter in response to proposed Federal Reserve appraisal and evaluation guidelines suggesting necessary changes to eliminate the undue influence of brokers on the appraisal and evaluation process, establish robust internal controls for the appraisal process during the loan origination process. Woodstock recommends additional quality controls for institutions purchasing mortgage-backed securities.

Woodstock Institute supports the Illinois Department of Financial and Professional Regulation proposed changes to the definition of a short-term title-secured loan under the Consumer Installment Loan Act and suggests eight additional protections necessary to eliminate other abuses common to the automobile title loan industry.

Woodstock Institute supports the OCC rule implementing the Housing and Economic Recovery Act of 2008 which permits national banks to make qualified direct or indirect investments in community development projects totaling 15 percent of their combined tier one and tier two capital, so long as 51 percent of the portfolio benefits low- and moderate-income communities or families.

Written testimony outlining the five key principles of the Monsignor Egan Campaign for Payday Loan Reform presented to a working group on Short-Term Installment Lending sponsored by State Representative Julie Hamos.

Comment on a Federal Reserve proposal requesting that the Federal Reserve set a maximum permissible default or penalty rate for credit cards and include additional borrower protections, eliminate double-cycle billing, eliminate universal default, forbid unfair payment cut-off times, and add additional borrower protections.